SecProbe.io

CORRESP
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Mark Selinger

Tel 212.801.9221

Fax 212.801.6400

Mark.Selinger@gtlaw.com

October 31, 2023

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Technology

100 F Street, N.E.

Washington, D.C. 20549

    Attention:
    Mark Brunhofer

Sharon Blume

Eric Envall

Sonia Bednarowski

    Re:
    INX Limited

    Form 20-F for the Fiscal Year Ended December 31, 2022

    Filed May 1, 2023

    Form 6-K

    Filed August 15, 2023

    File No. 000-56429

Dear Mr. Brunhofer:

On behalf of INX Ltd. (the “Company”
or “INX”), we are writing to submit the Company’s responses to comments of the staff (the “Staff”) of the
Division of Corporation Finance of the Securities and Exchange Commission (the “Commission,” or the “SEC”) dated
September 1, 2023, relating to the above referenced Form 20-F for the fiscal year ended December 31, 2022 and Form 6-K filed by the Company
on August 15, 2023 (File No. 000-56429). For ease of review, we have set forth below each of the numbered comments of your letter and
the Company’s responses thereto.

Form 20-F for the Fiscal Year Ended December
31, 2022

Risks Related to Blockchain Assets

Each blockchain network, including the Ethereum
network, is dependent, page 8

 1. We note your disclosure here that you “are issuing the INX Token, an ERC20 blockchain asset”
and your disclosure in the section titled “The INX Token” on page 60 where you identify INX Token as “an ERC-1404 blockchain
asset.” In future filings, please revise your disclosure to clarify the type of asset that the INX Tokens are.

Response:

The Company respectfully acknowledges
the Staff’s comment, and intends to include the following disclosure in its Annual Report on Form 20-F:

The INX Token operates on
the ERC-1404 blockchain standard, a modified version of ERC-20 that introduces two additional functions:

1. Detect Transfer Restrictions: This feature allows for the
identification of transfer restrictions, providing enhanced security and compliance; and

2. Human-Readable Error Messages: ERC-1404 enhances user experience
by offering clear and understandable error messages when a transfer is likely to fail.

Furthermore, ERC-1404’s compatibility
with existing wallets and exchanges designed for ERC-20 simplifies integration, making it convenient for a wide range of users and platforms.

Adding crypto assets to, or removing from our
platform, page 15

 2. Please tell us whether you continue to list MATIC or any other crypto assets that the Commission has
identified as securities. Also revise the first risk factor on page 14 to address the risk of having listed MATIC on your platform or
advise.

Response:

In response to the
Staff’s comment, the Company respectfully notes that, with respect to the Company’s INXS platform, as soon as the
Commission or any other applicable regulatory authority or a court, having final determinative authority, determines that a
supported crypto asset is a security, the Company promptly initiates the delisting process, rendering it unavailable on the
platform, as it has already done with MATIC, SAND, and other crypto-assets, which are no longer listed on its platform.

In addition, the Company intends
to revise the following language in the risk factor, as follows:

With respect to the
Company’s INXD platform, “if the Company fails to properly characterize a digital asset listed for trading under applicable securities
laws, it may be subject to regulatory scrutiny, inquiries, investigations, fines, and other penalties, which may adversely affect the
business, operating results, and its financial condition.

There can be no assurances
that we have properly characterized in the past, or that we will properly characterize in the future, any given crypto asset as a security
or non-security for purposes of determining whether our platform will support trading of the crypto asset, or that the SEC, foreign regulatory
authority, or a court, if the question was presented to it, would agree with our assessment. If an applicable regulatory authority or
a court, having final determinative authority on the subject, were to determine that a supported crypto asset that was previously offered,
sold, or traded on our INX Digital platform, or that is currently offered, sold, or traded on our INX Digital platform, is a security, we could be subject
to judicial or administrative sanctions for failing to offer or sell the crypto asset in compliance with the registration or exemption
requirements. Such an action could result in injunctions, cease and desist orders, as well as civil monetary penalties, fines, and disgorgement,
criminal liability, and reputational harm. Customers that traded such supported crypto assets on our platform and suffered trading losses
could also seek to rescind a transaction that we facilitated on the basis that it was conducted in violation of applicable law, which
could subject us to significant liability. Furthermore, if we remove any crypto assets from trading on our platform for any reason, our
decision may be unpopular with users and may reduce our ability to attract and retain customers, especially if such assets remain traded
on unregulated exchanges, which includes many of our competitors.

    2

Further, if Bitcoin, Ethereum,
or any other crypto asset that we are either currently supporting, or that we supported in the past, is deemed to be a security under
any U.S. federal, state, or foreign jurisdiction, or in a proceeding in a court of law or otherwise, it may have adverse consequences
for such supported crypto asset. For instance, all transactions in such supported crypto assets would have to be registered with the SEC
or other foreign authority, or conducted in accordance with an exemption from registration, which could severely limit its liquidity,
usability and transactability. Moreover, the networks on which such supported crypto assets are utilized may be required to be regulated
as securities intermediaries, and subject to applicable rules, which could effectively render the network impracticable for its existing
purposes. Further, it could draw negative publicity and a decline in the general acceptance of the crypto asset. Also, it may make it
difficult for such supported crypto assets to be traded, cleared, and held in custody as compared to other crypto assets that are not
considered to be securities.”

 3. In future filings, please revise this section to include a discussion regarding the adding or removing
of crypto assets to INXS in addition to your discussion of adding or removing crypto assets to INXD.

Response:

The Company respectfully acknowledges
the Staff’s comment, and intends to include the following disclosure in its Annual Report on Form 20-F:

The
Company has established a proactive internal procedure for the delisting and removal of assets from its INXS platform. When a coin or
token no longer meets our compliance and/or listing standards due to variety of reasons including, changes in the industry or other pertinent
considerations, our compliance department, and the commercial team, to the extent required, undertake a comprehensive review, which
may lead to the delisting of the relevant asset(s). We believe that this process reflects best practices and serves to safeguard both
the Company and its users and customers.

During the review conducted
by the compliance department, several factors are taken into account. While this list is not exhaustive, it provides insight into some
of the key considerations:

 ● Commitment of the Team to the Project

 ● Level and Quality of Development Activity

 ● Trading Volume and Liquidity

 ● Stability and Security of the Network Against Attacks

 ● Network and Smart Contract Stability

 ● Nature and Level of Public Communication

 ● Responsiveness to Periodic Due Diligence Requests

 ● Evidence of Unethical, Fraudulent Conduct, or Negligence

 ● Contribution to a Healthy and Sustainable Crypto Ecosystem

 ● Relevance to Recent Regulatory Developments

    3

During 2023, we decided to
delist and cease trading the following tokens:

 ● MATIC

 ● LINK

 ● MANA

 ● YFI

 ● COMP

 ● SAND

All relevant trading pairs,
including those associated with the above-mentioned tokens, have been removed from our trading platform.”

Our securities business exposes us to capital
requirements and regulatory risk, page 22

 4. In future filings, please clarify if you are affiliated with any registered broker-dealers other than
INX Securities, LLC.

Response:

The Company respectfully acknowledges
the Staff’s comment, and intends to include the following disclosure in its Annual Report on Form 20-F:

“The Company is not
affiliated with any other registered broker-dealer other than INX Securities, LLC.”

We accept certain cryptocurrencies as fees
for services, page 30

 5. We note your disclosure that you accept
                                            certain crypto assets as fees for services and your reference to your fee schedule (https://www.inx.co/fee-schedules/)
                                            for further information. In future periodic reports, in addition to any references to your
                                            fee schedule, please include a list of the crypto assets that you accept as fees for services
                                            as of that period, and, in your response, please provide a list of the crypto assets that
                                            you accept as fees for services.

Response:

The Company respectfully acknowledges
the Staff’s comment, and intends to include the following disclosure in its Annual Report on Form 20-F:

“For trading securities
on the Company’s ATS, fees are charged exclusively in US Dollars, and no crypto assets can be used as payment for these services. However,
on the digital crypto platform, fees are paid in the same currency as the currency a customer receives from the trade itself. The crypto
assets the Company accepts as a payment for fees depends on the crypto assets listed for trading on the platform which are as follows:

AAVE

AVAXC

BTC

CRV

ETH

FTM

LTC

UNI

USDC

ZEC”

    4

Information on the Company

History and Development of the Company

Subsidiaries, page 47

 6. In future filings, please disclose
                                            all of the crypto assets supported for trading on the INXD platform and revise your disclosure
                                            so that the lists of crypto assets disclosed on pages 47 and 55 are consistent with your
                                            disclosure on page F-11. In your response, please provide a list of the crypto assets you
                                            currently support for trading on the INXD platform.

Response:

In response to the Staff’s
comment, we will ensure that the disclosure of digital assets offered by the Company is consistent within the Form 20-F and the attached
consolidated financial statement disclosures. The Company respectfully advises the Staff that it intends to include the following table
of all the crypto assets that the Company currently offers on its platform, in its Annual Report on Form 20-F.

As of October 1, 2023,
the following crypto assets are supported for trading on the INX Digital platform:

AAVE

AVAXC

BTC

CRV

ETH

FTM

LTC

UNI

USDC

ZEC

    5

INX Trading Solutions, also known as INX.One,
a Single Regulated Ecosystem for Trading

Blockchain Assets, page 55

 7. We note your disclosure on page 55
                                            that you have established transaction fees as a percentage of the trade price of each
                                            trade executed on INX.One and that such fees must be paid in the currency or crypto currency
                                            that is received by the customer for the purchase or sale associated with the transaction
                                            fee. In future filings, please disclose how you determine the trade price in USD and the
                                            value of the crypto currency charged as fees.

Response:

The Company respectfully advises
the Staff that it intends to include the following revised disclosure in its Annual Report on Form 20-F:

“Transaction Fee
Transparency. We have established transaction fees as a percentage of digital assets received by the buyer and a percentage of consideration
paid by the seller in each trade, which could be denominated in fiat or in a digital asset. For trades in digital assets on INX.One, transaction
fees are charged by deducting the fee amount from the asset that is received by the buying and selling customer in a trade. For trades
in security tokens on INX.One, the trading fee is deducted from the buyer and the seller in US Dollars as a percentage of the trade value
in US Dollars. The transaction fees of our trading platforms are published and updated from time to time on our website available at https://www.inx.co/.”

We respectfully refer the
Staff to the following examples of both types of transactions:

For crypto currencies:

Person A sells 1 bitcoin to person B for $25,000
(assume the trading fee is 0.5% for both person A and B).

Person A receives $25,000 in the trade and needs
to pay 0.5% of $25,000 as fee to INX (0.005*25000=$125 fee).

Person B receives 1 bitcoin in the trade and needs
to pay 0.5% of 1 BTC as fee to INX (0.005*1=0.005 BTC fee).

For securities:

Person A sells 1000 INX tokens to person B for
$700 (assume the trading fee is 0.5% for both person A and B).

When the order is inserted, the Company is instructed
by the buyer to deduct (person B in this example) the trade value amount, plus the fee. In such a case, the Company will deduct from the
buyer’s balance $700 + 0.5%*700 = $703.5 (i.e., the buyer’s fee is $3.5).

After the match, the buyer (person B) will receive
1000 INX tokens, and the Company will keep $3.5 out of the $703.5 (i.e., the buyer paid the fee).

The seller (person A) will receive $700, less
the fee. The Company is instructed by the seller to deduct the seller’s fee (0.5%*700 = $3.5) from the trade value of $700, and the Company
will receive another $3.5 in fees from the seller.

    6

 8. We note your disclosure that on the
                                            INXS platform, the security tokens are listed in foreign jurisdictions that you believe you
                                            have the right to operate in. In future filings, please identify the services you offer in
                                            each jurisdiction, including the services offered on the INXD platform.

Response:

The Company respectfully advises
the Staff that it intends to include the following revised disclosure in its Annual Report on Form 20-F:

INX Digital trading platform,
operates within the US, however, users from other regions may independently access our platform and engage in trading activities involving
securities or cryptocurrencies, subject to compliance with the Company's policies and procedures.

On the INXS platform, the
security tokens are available for trading in all 50 U.S. states, as well as in two U.S. territories and other foreign jurisdictions that
we believe we have the right to operate in. For certain of our security tokens listed on our INXS platform, in addition to trading services,
the Company also offers broker-dealer of record services for certain primary offerings in compliance with local laws.

Technology and Product Development, page 56

 9. We note your disclosure that that
                                            “[t]he trading platforms to be operated by each entity will support “straight
                                            through processing” of orders received from customers.” In future filings, please
                                            clarify how INXD an